The Iowa Supreme Court issued a split decision Thursday in a case involving gross negligence claims against multiple corrections officers following the death of a colleague during a prison escape attempt in 2021.
Sara Montague, the widow of corrections officer Robert McFarland, brought the lawsuit against 25 of her late husband's former co-workers, alleging their negligence contributed to his death when two inmates killed him during an escape attempt at an Iowa state prison. The court's ruling in *Montague v. Skinner* allows portions of her lawsuit to proceed while dismissing other claims.
The Iowa Supreme Court affirmed in part and reversed in part the district court's earlier denial of the defendants' motion to dismiss the gross negligence claims. Justice Mansfield delivered the opinion for the unanimous court, which remanded the case for further proceedings.
According to court documents, McFarland was murdered by two inmates during a 2021 escape attempt at the prison where he worked. Montague alleges that serious security lapses by her husband's fellow officers allowed dangerous inmates to enter the prison infirmary while armed, creating the conditions that led to McFarland's death.
The case highlights the complex legal landscape surrounding lawsuits against state employees. As the court noted in its opinion, there are "potential obstacles to suing State of Iowa employees," and the case required the justices to consider several of these legal hurdles.
Montague filed the lawsuit individually, as the parent and next friend of the couple's minor child C.M., and as the authorized representative of McFarland's estate. She named 25 defendants, including corrections officers Beth Skinner, William Sperfslage, Samantha Tucker-Sieberg, Sarah Holder, Daniel Clark, Jeremy Larson, and others who worked alongside her husband at the time of the incident.
The defendants, represented by Iowa Attorney General Brenna Bird's office, appealed the district court's decision that would have allowed all of Montague's gross negligence claims to proceed to trial. Solicitor General Eric Wessan and Deputy Solicitor General Patrick Valencia argued the case for the state employees, while Montague was represented by attorneys from Gourley, Rehkemper & Lindholm and Skinner & Paschke.
The Iowa District Court for Jones County, presided over by Judge Michael Harris, had initially denied the defendants' motion to dismiss the gross negligence claims. The Supreme Court's mixed ruling suggests that while some of the negligence claims may proceed, others were properly dismissed under state law governing immunity for government employees.
The case raises important questions about the scope of liability for state corrections officers and the standards for gross negligence in workplace settings. Iowa law provides certain protections for state employees acting within the scope of their employment, but these protections may not extend to cases involving gross negligence or willful misconduct.
Gross negligence claims require plaintiffs to prove a higher standard than ordinary negligence, showing that defendants acted with reckless disregard for the safety of others. In the corrections context, this might involve allegations that officers failed to follow basic security protocols or ignored obvious dangers that could lead to inmate violence.
The 2021 prison escape attempt that claimed McFarland's life appears to have involved significant security failures that allegedly allowed inmates to access areas where they could harm staff members. The specific details of how the inmates obtained weapons and accessed the infirmary remain part of the ongoing litigation.
For Montague and her family, the mixed ruling represents both a victory and a setback in their quest for accountability in McFarland's death. While some claims against the corrections officers will proceed, others have been dismissed, potentially limiting the scope of damages that could be recovered.
The case also underscores the dangerous working conditions faced by corrections officers across Iowa and the nation. Prison violence against staff members highlights ongoing security challenges in correctional facilities and the need for robust safety protocols to protect both inmates and employees.
The Iowa Supreme Court's decision will likely influence future cases involving claims against state employees, particularly in the corrections context. The ruling clarifies the boundaries of gross negligence claims while maintaining certain protections for government workers performing their official duties.
As the case returns to the district court for further proceedings consistent with the Supreme Court's opinion, Montague will continue pursuing her remaining claims against the corrections officers she alleges were responsible for the security failures that led to her husband's death.
The remanded case will require the lower court to apply the Iowa Supreme Court's guidance on which claims may proceed and which must be dismissed, setting the stage for continued litigation in this tragic workplace death case.